United States v. Purham, 2015 U.S. App. LEXIS 13677

Purham pled guilty to conspiracy to distribute 280 grams or more of crack cocaine; he acknowledged the quantity at plea and faced a 20-year mandatory minimum.
On remand, the Seventh Circuit reversed a prior enhancement and required resentencing, limiting consideration of certain prior conduct as relevant conduct.
The district court recalculated Purham’s base offense level to reflect 280–gram quantity, then applied enhancements for firearm involvement, witness threats, multiple distribution residences, and managerial role; it subtracted two levels under the Drugs Minus Two amendment.
Criminal history score placed Purham in Category VI; total offense level 42 yielded a guidelines range of 360 months to life in prison.
The district court imposed a 324-month term (below guidelines), 120 months of supervised release, and a $100 special assessment, while also imposing two supervised-release conditions: (a) no gang association or gang colors, and (b) 20 hours/week of community service if unemployed after 60 days.
Purham appealed arguing the remand scope was exceeded, the sentence was unreasonable, and the two supervised-release conditions were improper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the remand scope allowed recalculation of base offense level	Purham argues remand was limited to correcting the error, not reweighing drug quantity.	Purham contends recalculation was improper beyond remand, effectively changing sentencing calculations.	Remand included redetermination of drug quantity; no excess in resentencing.
Whether the 324-month sentence is reasonable	Purham challenges the length as unreasonable given the guidelines and factors.	District court properly varianced below the guidelines within § 3553(a) and the below-range sentence is presumptively reasonable.	Sentence deemed reasonable; below-guidelines sentence preserved.
Whether the two supervised-release conditions (gang association and community service) are proper	Purham contends the conditions are vague or overbroad and not adequately tied to § 3553(a).	District court provided reasons tied to 3553(a) factors for both conditions.	Conditions vacated for community service and gang association; remanded for limited reconsideration.
Whether the district court properly explained conditions under 3553(a)	Purham argues the court did not provide sufficiently clear reasoning for the conditions.	Court gave stated reasons aligned with job training and deterrence.	Court’s reasoning acceptable but vacated the overeaching conditions for lack of precision under Thompson.

United States v. Barnes, 660 F.3d 1000 (7th Cir. 2011) (remand scope limited to discrete errors)
United States v. Liddell, 543 F.3d 877 (7th Cir. 2008) (presumption of reasonableness for below-guidelines sentences)
United States v. George, 403 F.3d 470 (7th Cir. 2005) (reasonableness of non-guidelines sentences)
United States v. Siegel, 753 F.3d 705 (7th Cir. 2014) (vagueness of supervised-release conditions)
United States v. Bryant, 754 F.3d 443 (7th Cir. 2014) (requirement to provide a reason for discretionary conditions of supervised release)
United States v. Thompson, 111 F.3d 368 (7th Cir. 2015) (vagueness and scope of supervised-release conditions)
United States v. Sewell, 780 F.3d 839 (7th Cir. 2015) (remand for reconsideration of conditions of supervised release)
United States v. Adkins, 743 F.3d 176 (7th Cir. 2014) (consideration of due process in conditions)
United States v. Neal, 662 F.3d 936 (7th Cir. 2011) (case law on discretionary sentencing factors)